John J. Zanath - Page 10




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          maintained the residence.  See id.  He testified that his “rent             
          arrangements are nominal,” and that he provides help around the             
          house for his elderly parents.  Any expenses petitioner incurred            
          while away from Aliquippa in 1996 were not traveling expenses               
          within the meaning of section 162(a)(2) and are not deductible              
          thereunder.  See id.                                                        
               We hold that petitioner is not entitled to a deduction in              
          any amount for employee business expenses.                                  
               The third issue for decision is whether petitioner is liable           
          for the section 6654(a) addition to tax for failure to make                 
          estimated Federal income tax payments for 1996.  This Court has             
          jurisdiction to review respondent’s determination of this                   
          addition to tax only if the taxpayer does not file a return for             
          the taxable year.  Sec. 6665(b)(2); Meyer v. Commissioner, 97               
          T.C. 555, 562 (1991).  In this case, petitioner did not file the            
          return until after the petition had been filed.  However, the               
          stipulation clearly states petitioner did file the return on                
          October 12, 2000, and a copy of the return is attached to the               
          stipulation as an exhibit.  We therefore lack jurisdiction over             
          this issue and cannot review respondent’s determination in this             
          regard.                                                                     
               The final issue for decision is whether petitioner is liable           
          for the section 6651(a)(1) and (2) additions to tax for failure             
          to file a return and pay the tax shown thereon.  Paragraph (1) of           






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